POWER March 2012 - 78

COMMENTARY
Has the Dust Settled?
By Bob Taylor
S
pring is around the corner. For many, spring marks a time
when we are glad that those dreary winter skies are replaced
with partial cloudy, rainy ones. In some areas, it is
the rain that washes away salt, ash, and residues from roadways
and aids in suppressing pollen in the air from blooming flora.
Spring cleaning often occurs to ensure our house is in order.
Plant outages are in bloom, and workers say farewell to wintertime
blues.
As our seasons transition, so may the fire and deflagration
hazards from coal and combustible dust that once were visible
and now may be out of sight. Yet often, what is out of sight presents
the greatest hazard and risk. So has the dust settled?
The Dangers of Combustible Dust
The U.S. Chemical Safety and Hazard Investigation Board
(CSB) started reviewing the hazards associated with combustible
dust after a series of lethal fires and explosions occurred
in 2003. In 2006, the board published a study that found
at least 281 dust explosions and fires occurred in the U.S.
between 1980 and 2005. They killed 119 workers and injured
718. As part of the report, the CSB urged the Occupational
Safety & Health Administration (OSHA) to enact regulations
for controlling dust hazards. OSHA, however, did not begin
the process of developing regulations until 2009.
Recently, the CSB released its new findings based on its
latest review of serious industrial events. According to its
review, there has been no change in the frequency of deaths
and injuries from dust accidents, despite more inspections
and the implementation of an OSHA education program.
The CSB report points out that there appears to be a trend
related to many of these incidents. Often, personnel are not
sufficiently trained in hazard recognition and analysis techniques.
In addition, there frequently is complacency about
the hazards of combustible dust. When these conditions exist,
history repeats itself and new industrial accidents happen.
OSHA's Combustible Dust Standard: Still a Work in Progress
OSHA continues down the path toward enacting a combustible
dust standard that would require many industries to better
control combustible dust hazards. It's a long, winding,
and tiring pathway, and it may take years before the standard
is enacted.
Recently, OSHA officials moved the proposed combustible
standard to its long-term agenda, despite pleas from the CSB
to put it on the fast track. In January, when OSHA published
its twice-yearly regulatory agenda, it included a note about
combustible dust regulations that reads " next action undetermined. "
One
hurdle OSHA has to overcome in passing the new
standard is to document its economic impact. Part of OSHA's
76
rulemaking process under the Small Business Regulatory
Enforcement Fairness Act (SBREFA) review is to give small
businesses the ability to participate in the process and give
their feedback about the financial impact of complying with
the proposed rule. Improvements to dust control systems
and other facility upgrades to help control combustible dust
typically require significant financial investment, which can
be a tough sell to businesses during these challenging economic
times.
Meanwhile, OSHA's Combustible Dust National Emphasis
Program (NEP) is very much alive. Under the NEP guidelines,
OSHA personnel are encouraged to inspect facilities that generate
or handle combustible dusts that pose a deflagration
or other fire hazard. OSHA can cite facilities using standards
defined by its NEP CPL 03-00-2008, including electrical installations,
housekeeping, hazard labeling, personal protective
equipment hazard assessment, and the employer's duty
to provide a workplace free from recognized hazards.
Currently, the National Fire Protection Association (NFPA)
has a number of combustible dust standards that are specific
to certain industries or commodities such as metal or wood.
However, the association has identified that there is a great
need for an overarching fundamental combustible dust standard.
Consequently, the NFPA has assembled a new technical
committee that is focused on developing a new standard
that deals with the fundamentals of combustible dust. Even
though the proposed standard is likely to be fast-tracked, it
may take several years before it actually comes to life.
Promoting Safe Practices in the Meantime
During the upcoming PRB Coal Users' Group annual meeting,
which will be colocated with the 2012 ELECTRIC POWER Conference
& Exhibition in Baltimore in May, attendees will hear
more specifics about the regulatory processes related to combustible
dust, learn about actions that may be taken to prevent
or control fire and deflagration hazards, and hear from
those who have been impacted by serious incidents involving
combustible dust. For example, attendees will be able to meet
Tammy Mizer, whose brother died in a combustible dust event
and find out how family, friends, coworkers, and communities
are affected. Her story is real and personal, and it's a springboard
to why the subject of safety is so critical.
During the first 30 days of 2012, our industry was impacted by
an average of one fire or deflagration per day. For many reasons,
little is known about these incidents, let alone shared, but they
continue to happen.
Is it time for spring cleaning? The dust hasn't settled, and if it
has, it's likely to be a deflagration risk. ■
-Bob Taylor is chairman of the PRB Coal Users' Group
(www.prbcoals.com).
www.powermag.com
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POWER March 2012

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